'Modern yoga' presentation slideshows
Modern yoga - powerpoint ppt presentation.
The History of Yoga
The History of Yoga. Ashley McNair. The Establishment of Yoga. the roots of Yoga can be traced as long as 5000 years back earliest reference to Yoga was found when archeological excavations where made in the Indus valley
Namo Gange- Introduction of Yoga
Yoga is derived from the Sanskrit word - Yuj which means union or joining. Literally, Yoga is one of the six systems of Indian philosophies which are composed by Maharishi Patanjali in-between 200-300 BC. Yoga is the science of life and an ideal way of living to achieve total health, peace and harmony. Ultimate goal of yoga is to achieve total health and a state of harmony between mind and body.\nNamo Gange is spreading awareness about Yoga & its Benefits through various activities.\n
What Is Yoga
Difference between traditional and modern yoga is that modern yoga mainly focus on fitness and traditional yoga is spiritual practice with a goal of union with the absolute with th
Modern Yoga Teacher Training | Awakened Warrior Yoga Teacher Training
The perfect fit for anyone who simply doesn't have the time in their busy schedule to commit to a group training and modern yoga teacher training in Los Angeles to New York.\nhttps:\/\/www.awakenedwarrior.yoga\/online-training
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Yoga Therapy for Modern Healing
Yoga therapy is the process of empowering individuals to progress toward improved health and well-being through the application of the teachings and practices of Yoga.\u201d \u2013 International Association of Yoga Therapists Yoga practitioners have always gushed about the perks of practicing the ancient art of yoga. Yoga is often looked upon as a means of physical activity and relaxation, but little do people know that it can also be used to improve your overall health and well-being.
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Yoga. Kari Dunn Buron 9/05. Kari Dunn Buron 9/05. Kari Dunn Buron 9/05. Kari Dunn Buron 9/05. Kari Dunn Buron 9/05. Kari Dunn Buron 9/05.
YOGA. Beginner Yoga Poses. Downward facing dog Transitional pose Resting pose Great strengthener in its own right. First yoga pose you encounter. Beginner Yoga Poses. Half Forward Bend Stretches the hamstrings Encourages good Spinal Alignment . Beginner Yoga Poses. Raised Hands Pose
Yoga. “WHAT IS YOGA?”. Yoga is a word from the ancient Sanskrit langue that means Union, the attachment and merger of the individual human consciousness with the cosmic consciousness.
YOGA. Name: Rani Khushalani Title of the speech: History of the yoga and their benefits. How yoga is Art, Science and Philosophy. Understand the roots of existence. It is old and around from 3000 BC’S. Started from Vedic period.
Delmar Francis. YOGA. Definition of yoga:. Yoga; commonly known for physical, mental and spiritual disciplines originating from East India. Traditions of yoga are found in Hinduism, Buddhism, Jainism and Sikhism. This sport is for males and females, it is a good muscular and strength exercise.
Yoga. The art of relaxation. History of Yoga. Techniques date back more then 5000 years Archeological sites found in the Indus Valley Built on three main structures Exercising, breathing, and meditation Not rooted in Hinduism Religion incorporates some practices.
Yoga for Modern Age - Latest
edic Oasis for Inspiration, Culture and Educati brings you
Yoga For Modern Age
Based on teachings of His Divine Grace
A.C. Bhaktivedanta Swami PrabhupadaFounder-Acharya of ISKCON
Life in fast lane
A general misconception
What is Yoga?Process of linking ourselves with the Supreme
Aga-yoga Yamathe eight divisional yoga systemcontrolling the senses
Niyama sana
following the rules and regulation
practicing the sitting posture breath control
Aga-yoga the eight divisional yoga system Pratyhracontrolling the senses from sense enjoyment
Dhra Dhynameditation
concentration
Aga-yoga as mentioned in Bhagavad-Gita Go to a secluded sacred
place. Lead a life of complete celibacy.
Aga-yoga as mentioned in Bhagavad-Gita Lay kua grass on the ground and then cover it with a deerskin, neither too high nor too low. Sit alone in a rigid posture, which cannot be
How many of us are willing to give this yoga system a try
5,000 years ago when conditions were much more favorable, Arjuna expressed his inability to practice such yoga, saying
Bhagavad-gt 6.34
For the mind is restless, turbulent, obstinate and very strong, O Ka, and to subdue it, I think, is more difficult than controlling the wind.
Different Yoga practices for Different Yugaskte yad dhyyato viu trety yajato makhai dvpare paricaryy kalau tad dhari-krtantrmad-Bhgavatam (12.3.52)
Satya-yugaMeditation on Lord Visnu
Tret-yugaPerforming Expensive Sacrifices
Dvpara-yugaElaborate Temple Worship
Kali-yuga(the present age)
Chanting Holy Names of the Lord
What do the major religions say about chanting the holy names of Lord?
ChristianityChrist glorified the Lords holy name by saying Our Father who art in Heaven, hallowed be Thy Name
SikhismGuru Nanak prayed In the ambrosial hours of the morning I meditate on the grace of the true name
Muslims repeatedly chant the sacred name of God - Allah
BuddhismBuddhists also practice repetition of the name of Lord Buddha (namu amida butsu)
Santana dharmaIt also recommends repetition of the holy names of the Lord, in form of mantra
What is a Mantra?
MAN + TRAMIND DELIVER
JapaHare Krishna Hare Krishna Krishna Krishna Hare Hare Hare Rama Hare Rama Rama Rama Hare Hare
SankirtanHare Krishna Hare Krishna Krishna Krishna Hare Hare Hare Rama Hare Rama Rama Rama Hare Hare
Scriptural References for chanting the Holy Names of Lord
Scriptural Referenceshare ka hare ka ka ka hare hare hare rma hare rma rma rma hare hare iti oaaka nmn kalikalmaa-nana nta parataropya sarvavedeu dyateKali-santaraa Upaniad
Scriptural References Aftersearching through all the Vedic literature one cannot find a method of religion more sublime for this age than the chanting of Hare Kali-santaraa Upaniad Krishna.
Scriptural References dvparyair janair viu pacartrais tu kevalai kalau tu nma-mtrea pjyate bhagavn hariNryaa-sahit
Scriptural ReferencesIn the age of Kali, people should simply chant the holy names of the Supreme Personality of Godhead.Nryaa-sahit
Scriptural References harer nma harer nma harer nmaiva kevalam kalau nsty eva nsty eva nsty eva gatir anyathr Caitanya-caritmta Adi-ll 17.21
quarrel and hypocrisy the only means of deliverance is the chanting of the holy names of the Lord. There is no other way. There is no other way. There is no other r Caitanya-caritmta Adi-ll 17.21 way.
ScripturalIn this age of References
Scriptural References kaler doa-nidhe rjann asti hy eko mahn gua krtand eva kasya mukta-saga para vrajetrmad-Bhgavatam (12.3.51)
Scriptural ReferencesMy dear King, although Kali-yuga is full of faults, there is still one good quality about this age. It is that simply by chanting the Hare Ka mah-mantra, one can become free from material bondage and be promoted to the transcendental kingdom. rmad-Bhgavatam (12.3.51)
Scriptural References
yajn japa-yajo smi
Bhagavad-gt 10.25
Scriptural ReferencesOf sacrifices I am the chanting of the holy names {japa}.Bhagavad-gt 10.25
Scriptural Referencesnmnm akri bahudh nijasarva-aktis tatrrpit niyamita smarae na kla etd tava kp bhagavan mampi durdaivam dam ihjani nnurgar Caitanya-caritmta Antyall 20.16
My Lord, O Supreme Personality of Godhead, in Your holy name there is all good fortune for the living entity, and therefore You have many names, such as Ka and Govinda, You have invested all Your potencies in those names, and there are no hard and fast rules for remembering r Caitanya-caritmta Antyall 20.16 them.
Scriptural ReferencesDevotional service, beginning with the chanting of the holy name of the Lord, is the ultimate religious principle for the living entity in human society.rmad-Bhgavatam 6.3.22
Scriptural ReferencesThose who are actually advanced in knowledge are able to appreciate the essential value of this age of Kali. Such enlightened persons worship Kali-yuga because in this fallen age all perfection of life can easily be achieved by the performance of sakrtana.rmad-Bhgavatam 11.5.36
Dos of Chanting
Dos for chanting the mahmantra
Chant the paca-tattva mantra before starting to chant the Hare Krishna mah-mantra
Paca-tattva mantra r-ka-caitanya prabhunitynanda r-advaita gaddhara rvsdi-gaurabhakta-vnda
Chant audibly(loud enough to hear the mantra)
Pronounce each name distinctly
Chant with respect, devotion & concentrati on
You can chant in any place, sitting or walking, facing any direction
recommended to chant during the early morning hours (brhma-muhrta)
You can chant at any time However it is
You can chant either before or after taking bath
It is recommend ed to chant by keeping count
(preferably on a Tulas ml having 108 beads)
Donts of Chanting
Donts for chanting the mahmantra
One should not chant only a portion of the mah-mantra
One should not chant on the Krishna bead of the japa ml
One should not chant while reading a book, or newspaper, or watching TV etc.
Benefits of Chanting
Freedom from the reactions of sin
Relief from unwanted drives & habits
In our present condition, we are slaves to any whimsical thoughts and desires.
Benefits of Chanting Freedom from anxiety and stress Peace of mind Real Happiness Enlightenment
What people say about chanting Hare Krishna?
Its really a process of having realization of God.George Harrison
Everything started happening for me when I began chanting Jean Claude Halliche Youngest Director Hare Krishna. of 3M Inc. - France(29 year old)
Chanting Hare Krishna has made a tremendous impact in my life. Albert Brush FordOwner - Ford Motors
I've been chanting Hare Krishna for many years, and I've never found anything more pleasurable. Just try to chant 5-10 minutes a day for a week and you'll feel the
N.D. Desai Leading Indian Industrialist(Apar Limited, GE Apar Lighting, CEMA Tubes, Apar Infotech)
Chanting Hare Krishna has helped me face all the ups and downs in my life with a great confidence and peace of mind.
Hrishikesh Mafatlal CEO - Mafatlal Fabrics
Chanting helped me give up bad habits. It changed my vision of Anne Schaufuss things. Dutch Model
By starting to chant Hare Krishna, I feel tremendous Vicki Overton happiness. leading European Model
Marco Ferrini
Chanting makes me feel close to God.
Italys top furniture designer
mantra significantly reduces stress, depression, & the mode of ignorance and considerably increases mode of
David WolfMaster of Social Service Program at Florida State UniversityResearcher for studying the effects of chanting Hare Krishna Mah-mantra.
If I start my day on a spiritual note by chanting Hare Krishna, I can make it through the day in a pleasant mood. Stephen FarmerHealth food store owner
Chanting has opened my eyes to things I never noticed. Its like beautiful music a very peaceful feeling, very satisfying. Mrs. Grace Acquistapace Housewife
When I am stressed out, I chant. Its one thing which charges my batteries. It clears my mind and brings me back in focus.
Paul Bleier Printing Executive
When Im nervous I find chanting very claming. I dont get shaken up at little things. Mrs. Sally Raleigh Merchandiser
towards life is lot more brighter, after starting to associate with Hare Krishna devotees and chanting the mah-
Bruce Klienberg Army Officer
Ive noticed that as chanters progress from one level to deeper level, they become more realistic, Dr. Donald R. Tuck more tolerant and more Associate Professor, Western Kentucky University energetic.
You can also chant Hare Krishna Hare Krishna Krishna Krishna Hare Hare Hare Rama Hare Rama Rama Rama Hare Hare and be happy THE END
The Complete Guide to Yin Yoga · in Yoga is a part of the original Hatha Yoga tradition. In its modern incarnation, Yin Yoga combines the influ-ences of Indian Yoga with Chinese
Modern Yoga Masters Lineage tree
Development of Modern Yogamodernyogaresearch.org/wp-content/uploads/2016/05/... · The Development of Modern Yoga: A Survey of the Field Abstract: Yoga is now found in urban centres
Eugene Rawls- Handbook of Yoga for Modern Living
YOGA IN MODERN TIMES,.docx
Yoga and its Relevance in the ModeRn tiMes
Yoga Teacher Training...Teaching and Practicing Restorative Yoga and Savasana 3 Introduction: Stress is a part of modern life. But fortunately, yoga provides us with the tools to use
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DEPARTMENT OF PHILOSOPHY, A.M.U. Modern …iv) Yoga: Nishkama Karma Yoga of Gita; Patanjali’s Eight-fold Yoga UNIT- II (i) Carvaka: Epistemology; Metaphysics
Sit Down, Be Quiet: A modern guide to yoga and mindful living
by Modern Collection - First Impressionsfirstimpressionskitchens.co.uk/wp-content/...Modern... · MODERN LIVING Combining real craftsmanship, expert knowledge and the latest designs
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Yoga Presentation templates
Are you familiar with the famous spiritual and physical practice from india yoga is a healing practise carried by the hinduists and has now become so popular that now about 36 million people in the u.s consider themselves “yoguis”, that is, people who practise yoga. are you one among them then use these relaxing templates to speak everything about the asanas and their benefits to body and soul.
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Yoga Workshop
Time to be kind to your body with this workshop template! This Memphis design is cool and creative: there are organic shapes in the background together with patterns of hand-drawn dots and illustrations of plants and flowers. We have also added pictures of people doing yoga outside that contrast with...
International Yoga Day
Yoga is not only a mental and spiritual practice, it also requires strength, flexibility and lots of motivation. This complete sport practice was born in India and has become worldwide known ever since the International Yoga Day was recognized in 2011 by the United Nations. As the Prime Minister of...
Meditation and Mindfulness IG Posts
Meditation helps maintain an emotional balance essential for good health, and it's a technique that more and more people are practicing. If you want to encourage this healthy practice among your social media followers, here's the perfect template for it. It is created in Instagram post format, and has a...
The Practice of Yoga
Did you know that people have been practicing yoga since the 17th century BC? Amazing, isn't it? Yoga is a physical and mental discipline with origins in India that focuses on freeing the mind and meditation. Slidesgo brings you a template for Google Slides and PowerPoint to present the content...
Cute Yoga Academy Minitheme
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Restorative Yoga Workshop
Yoga has such a wide range of asanas, that it can even be healing, apart from strengthening, relaxing and calming. An asana is a position or movement in hatha yoga, and each of them has a different function. In the original Sanskrit book, there were over 84 million asanas, imagine...
Kundalini Yoga Workshop
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Meditation Break Business Meeting
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Yoga Workshop with Stickers
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Mindfulness Session to Celebrate International Mind-Body Wellness Day
Would you say you have a balanced body and mind? International Mind-Body Wellness Day is around the corner and we have thought that a mindfulness session is perfect to promote this mindset! Download this template and prepare a session where your body and mind become one. Speak about its history,...
Yoga Infographics
We have the perfect remedy to make your presentations more relaxing: infographics with yoga poses! Represent your data visually with these designs and talk about benefits of practicing this discipline. Actually, the topic is up to you, since these are completely editable. There are maps, charts, diagrams, timetables... Connect with...
Vinyasa Yoga Workshop
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- 1. YOGA The way of life
- 2. Contents: What is YOGA? Origin Terminology Purpose History Reception in west Benefits Yoga techniques Conclusion
- 3. What is YOGA? Yoga is the physical, mental and spiritual practices which originated in ancient India with a view to attain a state of permanent peace of mind in order to experience one’s true self.
- 4. Origin ♦Yoga is the stilling of the changing states of mind. ♦The origins of Yoga are a matter of debate. It may have pre-Vedic origins.
- 5. Terminology In Vedic Sanskrit, the meaning of word Yoga is “to add”, “to join”, “to unite” or “to attach”.
- 6. Purpose The ultimate goal of Yoga is Moksha (liberation) through the exact definition of what form this takes depends on the philosophical or theological system with which it is conjugated.
- 7. History Several seals discovered at Indus Valley Civilization sites depict figures in positions resembling a common Yoga or meditation pose.
- 8. Reception in west ♦ Gurus from India introduced Yoga to the west following the success of Swami Vivekananda in the late 19th and early 20th century. In 1980’s , yoga became popular as a system of physical exercise across the western world. This form of Yoga is often called Hatha Yoga.
- 9. Benefits Many studies have determined the effectiveness of Yoga as a complementary intervention for cancer , asthma and heart disease.
- 10. Benefits In a national survey, long-term Yoga practitioners in the United States reported musculo-skeletal and mental health improvements.
- 11. Yoga techniques There are different yoga techniques. The most common among them are: Surya namaskar Meditation Pranayama
- 12. Yoga techniques Surya namaskar : It is a salutation to the sun. It is known to ease stress and give you peace of mind besides increasing your levels of concentration.
- 13. Yoga techniques Dhyana(meditation) : It is the state of mind wherein there are no sensory thoughts. It leads to a deeper level of relaxation, reduces anxiety, decreases muscle tension and headache.
- 14. Yoga techniques Pranayama : It means “a pause in the movement of breath”. It increases the spiritual power and confers cheerfulness and inner peace.
- 15. Conclusion Yoga , as a mindfulness practice, can help correct basic limitations of the mind by improving self awareness, self control and self esteem. The best way to understand Yoga is: TRY IT OUT YOURSELF! THANK YOU.
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Modern Yoga PowerPoint Template
Yoga illustration powerpoint template.
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Sunnyvale / Yoga
We offer a mix of yoga styles to help each and every body find their balance—whether yoga is your main thing or a part of your cross-training plan. While we honor yoga tradition, we value modern health and wellness sciences. Categories of yoga include Vinyasa, Hatha, Gentle, and Specialty. Within each category, we offer the styles tailored to our unique community of teachers and students.
Flow with your breath. Vinyasa classes ignite inner fire, improve cardiovascular fitness, make the spine more supple, and develop total-body coordination. A wide variety of poses link breath and movement, combined with sun salutations and standing postures.
Price: Day Pass | Member Price: Free
Slow Flow takes its time savoring every pose and transition. Like all Vinyasa classes, a wide variety of poses link breath and movement, combined with sun salutations and standing postures.
Power Flow classes are a strong, challenging version of Vinyasa classes. The focus will be on strength, endurance, stability, and may include more arm balance and inversions. Like all Vinyasa classes, a wide variety of poses link breath and movement, combined with sun salutations and standing postures.
Foundations
Great for beginner and experienced students alike, this class is designed to give you a language and understanding of poses, techniques and transitions involved in a yoga practice. Not specifically an easy class, it is deisnged to get you feeling stable, balanced, at ease and accomplished in your practice this class is goood not just for beginners but also for students looking to fine-tune their practice.
Similar to our other flow classes, expect to move with your breath with the additional focus on strengthening your whole core.
Stretch deeply. Yin postures are held for longer periods of time to stimulate and release connective tissues. Various props, such as myofascial release balls, are often used for greater decompression. If props are recommended, the instructor will give options for props commonly found at home at the beginning of class.
Iyengar Yoga South Bay
Develop strength, flexibility and a feeling of well-being from your very first class., new student special.
3 classes for $39.00.
Must be used within three weeks of the first class.
Current students may gift this offer for a friend.
Yamas & Niyamas in 2023
New class offerings.
Tuesday Restorative with Louiza
- 7:30-8:45 PM
Friday Online with Ruchi
- 12:00-1:15 PM
- Starts March 17
A class for every body!
Yoga for Healthy Bones with Jito
Saturday, March 11 & 18 1:00-3:00 PM
Discounted fees end March 4
Register here
No drop-ins
Learn classic yoga postures focusing on alignment
We start with the body and teach classic yoga postures with an emphasis on alignment so that strength and flexibility develop concurrently. Even after one’s first class, a feeling of well-being is experienced as the ancient yogis and now modern science concur that there is a direct relationship between one’s body and mind.
From action and doing comes reflection. Over time we help the student develop greater sensitivity to what they are experiencing in the pose. We do this with specific instructions, a prop or with consent, hands on adjustment. The sensitivity and awareness that develops is the seed that enables a transformation in one’s outward pose and inner experience. Thus from your first class yoga is an evolving transformative practice.
Words fail to convey the total value of yoga. It has to be experienced.
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Vintage California Modern Fireplace Log Holder by Gene Tepper
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- Item Details
- About the Seller
- Creator Gene Tepper (Designer)
- Dimensions Height: 15 in (38.1 cm) Width: 18.25 in (46.36 cm) Depth: 18 in (45.72 cm)
- Style Mid-Century Modern (Of the Period)
- Materials and Techniques Brass , Iron , Steel
- Place of Origin United States
- Period 1950-1959
- Date of Manufacture 1950s
- Condition Good Wear consistent with age and use. In good condition with patina on handles and metal. See photos.
- Seller Location San Jose, CA
- Reference Number 1stDibs: LU1582215119821
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Johnson v. Transportation Agency, Santa Clara County, California - PowerPoint PPT Presentation
Johnson v. Transportation Agency, Santa Clara County, California
Johnson v. transportation agency, santa clara county, california genevieve mackay, brent movitz, kaitlin powell affirmative action since johnson 2003 (same day as ... – powerpoint ppt presentation.
- Genevieve Mackay, Brent Movitz, Kaitlin Powell
- Foundation of Affirmative Action
- 1896 Plessy v. Ferguson
- Facts Plessy refused to sit in a rail carriage designated for African Americans. He was convicted of violating a Louisiana statute which segregated trains.
- Rule Segregation was did not violate the 14th amendment as long as the facilities were substantially equal.
- Rationale Legislation and law could not change discriminative attitudes in society
- 1954 Brown v. Board of Education
- Facts African Americans wanted to attend a white public school.
- Rule The 14th Amendment prohibits public schools from segregating based on race.
- Rationale Separate but equal is a fallacy. However, because Justice Warren conformed his holding to the facts of the case, he provided little insight as to what protections should be afforded to African Americans or others who face discrimination.
- 1961 Equal Employment Opportunity Commission (EEOC)
- President Kennedy signed an Executive Order which formed the EEOC. The order promoted affirmative action to prohibit discrimination based on race, creed, color, or national origin.
- 1963 Equal Pay Act
- Passed by Congress before Kennedys assassination, the Equal Pay Act stated that private companies had to pay women the same compensation as men for performing the same work.
- Lilly Ledbetter Act http//vimeo.com/3097801
- 1964 The Civil Rights Act of 1964
- All persons within the jurisdiction of the United States shall have the same rights . . . and equal benefit of all laws . . . as are enjoyed by white citizens. 42 U.S.C.A 1981(a) (West 2009). After Kennedys assassination, during Johnsons presidency, in spite of the protests of Southern Democrats, the U.S. Congress passed the Civil Rights Act.
- Johnson Audio
- What ideal of freedom is our generation forging, expanding, and renewing?
- Domestically? Internationally?
- Does our generation work to widen opportunities for race/sex-based minorities?
- 1964-1967 Johnson and Affirmative Action
- You do not take a person who for years has been hobbled by chains, and liberate him, bring him up to the starting line of a race, and then say, You are free to compete with all the others, and still justly believe that you have been completely fair. Thus, it is not enough just to open the gates of opportunity, all of our citizens must have the ability to walk through those gates.
- President Johnson speaking at Howard University after Congress passed the Civil Rights Act of 1964. Urofsky, Affirmative Action on Trial Sex Discrimination in Johnson v. Santa Clara at 17.
- From 1965-1967 Johnson signed three Executive Orders which required federal contractors to recruit, hire and promote minorities and women.
- Affirmative Action Challenged in Court
- 1971 Griggs v. Duke Power Co.,
- Facts Duke Power Company required employees to have a high school diploma and pass a standardized general intelligence test in order to be promoted.
- Rules Title VII of the Civil Rights Act of 1964 expressly prohibits employment discrimination. Barriers that favor white employees in employment decisions must be removed.
- Employment actions that appear race neutral, but have a disparate impact are discriminatory.
- Rationale Justice Burger reasoned that a high school diploma and the standardized tests were not related to job performance. Burger explained that because African Americans received inferior schooling they were unlikely to perform as well on tests as the white workers who received superior schooling. Burger stated that Congress has now required that the posture and condition of the job seeker be taken into account.
- 1978 Regents of U. of Cal. v. Bakke
- Facts Allan Bakke, a white male, sued the University of California when it denied him admission to medical school while it reserved sixteen out of one hundred spots for minority students.
- Rule An affirmative action plan which includes the use of quotas unconstitutionally discriminates against non-minorities under the 14th Amendment and Title VI of the Civil Rights Act of 1964 (prohibits recipients of federal funds to discriminate based on race).
- Rationale Foreshadowing difficult affirmative action decisions, the Court had a plurality decision. However, Powells opinion has been relied on in proceeding cases.
- Powell stated that affirmative action plans are allowed under the Equal Protection Clause because the state has a substantial interest in promoting educational diversity. However, the universitys plan was flawed because it used quotas. Justice Powell explained that diversity that furthers a compelling state interest encompasses a far broader array of qualifications than race. By reserving sixteen spots for candidates based solely on race, the plan would not necessarily provide genuine diversity.
- The Affirmative Action Plan Balance reflected in Bakke
- Meg Greenfield, a writer at Newsweek, predicted the Courts decision. She suggested that although it seemed to be indecisive, the decision emphasized the balance needed for a productive affirmative action plan.
- 1) allowed employers to strive for equality in the workplace caused by past discrimination and
- 2) tightened the connection between the steps taken and the discrimination remedied so as to prevent unnecessary barriers for non-minorities
- 1979 United Steelworkers of Am. v. Weber
- Facts A white workers sued his employer after the company accepted an African American into a training program instead of Weber, even though Weber had more seniority.
- Rule Title VII permitted voluntarily adopted affirmative action plans in the private sector.
- Rationale Brennan explained that the companys plan was within the spirit . . . and intention of the legislature when it enacted the Civil Rights Act because the plan would open employment opportunities for African Americans.
- Justice Blackmun, in a concurrence, explained that Brennan ignored the plain meaning of Title VII. However, Blackmun explained that companies which have committed arguable violations of Title VII by discriminating in the past should be able to correct their misdeeds through affirmative action plans.
- Dissent Justice Rehnquist dissented and relied on the plain meaning and precedent in which the Supreme Court had written, Title VII is to provide an equal opportunity for each applicant regardless of race, without regard to whether members of the applicants race are proportionately represented in the work force.
- The Meaning of Discrimination
- The split in United Steelworkers mirrored the split in Bakke. On one side, the liberal Justices aligned with the premise that race-conscious policies could remedy past discrimination. On the other side, the conservative Justices clung to the value that in order to have a society free from discrimination, the laws of society must mandate that no type of discrimination is acceptable.
- 1980 Fullilove v. Klutznick
- Facts The Public Works Employment Act provided that in order to receive federal funds for public works, the recipient, for example a city or state, must award 10 of the funds to minority business enterprises (MBEs).
- Rule Congress can pass legislation with the goal of correcting past economic disparities among minorities without violating the 14th Amendment.
- Rationale The Court, once again in a plurality decision, reasoned that remedial programs allowed minorities to be lifted to a level in which they could effectively participate.
- Graduate of the University of Illinois at Chicago and the University of Illinois Law Review.
- Previous Experience
- Worked as a judicial clerk to Judge Manning of the United States District Court for the Northern District of Illinois.
- Lawyer at large Chicago-based firm where he specialized in complex commercial litigation and employment and civil rights litigation.
- Mr. Schoop became a partner at Laner Muchin in 2008 and represents employers in employment discrimination, wrongful discharge, employment, civil rights litigation.
- Mr. Schoop is a member of the American Bar Association, the Seventh Circuit Bar and the Federal Bar Association. He is an Associate Articles Editor for the Federal Civil Practice Section Council of the Illinois State Bar Association and has authored several articles regarding civil practice in the various federal courts within Illinois. Mr. Schoop authored the chapter on age discrimination in the 2007 edition of the Illinois Institute of Continuing Legal Educations Employment Discrimination Handbook.
- Diane Joyce and Paul Johnson both were contending for road dispatcher at Santa Clara Transportation Agency.
- Diane Joyce rebel rousing, skirt-wearing person
- Learned to stand up for her rights.
- Paul Johnson good ol boy
- Felt he deserved the job and she just got it for her gender.
- On the road crew different standards
- Joyce never fit in
- Fought to get the same opportunities as men.
- Santa Clara was only 3.4 Black, although the Hispanic population was 17.7 and the Asian population 7.7.
- While women were 36.4 of the Santa Clara labor force, only 22.4 of Santa Clara county employees were women.
- Most held low level positions conventionally held by women
- Santa Clara had many women in politics
- May explain support of Affirmative Action plan
- hiring, training, and promotion of minorities and womenin all major job classifications where they are underrepresented with a long-term goal of having a work-force with the same Agency labor force composition of minorities and women as in the area labor force.
- Idealistic long-term goals, but realistic short-term objectives.
- Achievable goals v. implementing quotas
- Diane Joyce very apprehensive. Everyone else confident.
- Johnson and Attorney thought clear-cut discrimination case
- County Attorney equally certain acted in discretion Difficult to explain why need affirmative action plan without recognizing past injustices.
- Judge Ignam?county affirmative action plan did not meet Weber standards.
- Narrow ruling Affirmative Action plan remains in tact with minor changes.
- Placed on short calendar at first, then given more time to argue.
- Handed down decision that Judge Ignam construed Title VII and Weber too narrowly and the Santa Clara Countys affirmative action plan met the Weber requirements.
- Paul Johnson already had Diane Joyces position Joyce in South Yard
- Johnson felt frustrated
- Inquires at public interest law firms
- The Supreme Court Decision
- Justice Brennan delivered the opinion of the court in which justices Marshall, Blackmun, Powell, and Stevens joined. The court held
- The Agency appropriately took into account Joyces sex as one factor in determining that she should be promoted. The Agengys Plan represents a moderate, flexible, case-by-case approach to effecting a gradual improvement in the representation of minorities and women in the Agencys work force, and is fully consistent with Title VII.
- Who Bears the Burden of Proof that the Agencys plan violates Title VII?
- Once Johnson established a prima facie case that race or sex had been taken into account in the Agencys employment decision, the burden shifts to the Agency to articulate a nondiscriminatory rationale for that decision (ie an affirmative action plan). Once the Agency had done so the burden shifted back to Johnson to prove that the plan was invalid and that the Agencys justification was pretextual.
- This burden shifting means that the Court had to determine two things
- 1. Was the Agencys affirmative action plan legal or did it violate Title VII?
- 2. Part 1 - Was the employment decision made pursuant to a plan prompted by concerns similar to those in the Weber case? Part 2 - Was the effect of the plan on males and nonminorities comparable to the effect of the plan in that case?
- The Rule from Weber . . .
- In determining the legality of the Agencys plan under Title VII the Court used the standard set forth in the Weber case. This rule stated that the plan must be designed to eliminate manifest racial imbalances in traditionally segregated job categories.
- The Court further determined that to meet this standard the employer must only point to a conspicuous imbalance in traditionally segregated job categories and not meet a prima facie case standard.
- Taken together this decision was grounded in the understanding that voluntary action on the part of the employer is crucial to furthering the purpose of Title VII and the idea that Title VII should not be read to thwart such efforts.
- Question 2, Part 1 . . . .
- Was the employment decision made pursuant to a plan prompted by concerns similar to those in the Weber case?
- Here the Court determined that the plan was developed to correct a manifold imbalance based on the fact that women did not hold a single position in this employment category at the time the decision was made to hire Joyce. Additionally the court considered the facts that the Agencys plan was temporary and flexible with a long term goal supported by short term goals aimed at eliminating rather than maintaining imbalances in the work force.
- Question 2, Part 2 . . . .
- Was the effect of the plan on males and nonminorities comparable to the effect of the plan in the Weber case?
- Here,as in Weber, the Court asked whether the Agencys plan unnecessarily trammeled the rights of male employees or created an absolute bar to their advancement. It determined that the plan did NOT do so because it did NOT . . .
- Set aside positions for women. The plan instead specifically stated that the goals established should not be construed as quotas that must be met. Instead the plan merely authorized consideration of affirmative action concerns when evaluating qualified applicants.
- The Last Consideration of the Court . . . .
- At the end of the decision the Court noted that it should be mindful of the Court and Congress consistent emphasis on the value of voluntary efforts to further the objectives of the law. This was brought up earlier in the decision to support not using the prima facie standard for the employer to develop an affirmative action plan as well. It is laid out in the final decision statement of the Court as well for emphasis.
- Proposition 209
- California passed which prohibits racial, ethnic, and gender preferences in public education, employment, and contracting. Allows economic status to be considered. Michigan has a similar law.
- California Regents revoke affirmative action plan
- 2003 Grutter v. Bollinger
- Facts A non-minority student sued the University of Michigans law school after she was rejected.
- Rule Diversity in education is a compelling state interest and a schools affirmative action plan that does not use quotas is not unconstitutional under the 14th Amendment, nor does it violate Title VI.
- Rationale OConnor relied heavily on Powells opinion in Bakke. She explained that the law schools affirmative action plan narrowly tailors the use of race in admissions decisions to further a compelling state interest in obtaining the educational benefits that flow from a diverse student body.
- Dissent Chief Justice Rehnquist dissented and claimed that the law schools system was a thinly veiled quota system. He claimed that the admissions process was not narrowly tailored to the goal of complete diversity, not just racial diversity. Rehnquist used actual application and admission data from the law school to show a direct correlation between the amount of a minority that applied and the amount that was accepted. For example, in 1995, 9.7 of the applicant pool was African American and 9.4 of the admitted class was African American.
- Justice Thomas, an African American, states that the U.S. Constitution abhors classifications based on race, not only because those classifications can harm favored races or are based on illegitimate motives, but also because every time the government places citizens on racial registers and makes race relevant to the provision of burdens or benefits, it demeans us all. Thomas quoted Frederick Douglass who said, And if the negro cannot stand on his own legs, let him fall. Your interference is doing him positive injury. What I ask for the negro is not benevolence . . . but simply justice. Id. at 350.
- 2003 (same day as Grutter) Gratz v. Bollinger
- Facts Jennifer Gratz, a Caucasian, applied to the University of Michigan undergraduate school and was rejected. The University of Michigans undergraduate admissions department used a selection index. Applicants could aggregate up to 150 points depending on factors including, GPA, in-state residency, alumni relationship, personal essay, academic performance, etc. A minority applicant would receive twenty points automatically, whereas other diverse qualities, such as geographic diversity or leadership and service were capped at five points. If a student received one hundred points he would be admitted.
- Rule An affirmative action plan for a university must be narrowly tailored to the legitimate end of educational diversity.
- Quotas are not narrowly tailored to the legitimate end of educational diversity.
- Rationale Chief Justice Rehnquist wrote the opinion of the Court and relied heavily on Powells rationale in Bakke. Rehnquist explained that no single characteristic automatically ensured a specific and identifiable contribution to a universitys diversity. Rehnquist emphasized the importance of considering each . . . individual, assessing all of his qualities . . . and . . . evaluating that individuals ability to contribute to the unique setting of higher education. Rehnquist found that the University had created a situation in which virtually every minimally qualified . . . minority applicant would be accepted regardless of his individual characteristics.
- 2009 Ricci v. DeStefano
- Facts The city of New Haven, Connecticut, used a job-related test to decide who would be considered for promotions among its firefighters. The results of the test revealed that whites outperformed their Hispanic and African American counterparts. Hence, if the city certified the results, it would promote a disproportionate amount of white firefighters. The city feared that the test had created a disparate impact on African Americans by discriminating against them and thusly violated Title VII. Therefore, the city did not certify the results.
- Disparate Treatment An employer cannot discriminate based on race.
- Disparate Impact Employment actions that appear race neutral, but have a disparate impact are discriminatory.
- An employer has a defense to a disparate impact claim if it can show that the practice is job related for the position in question and consistent with business necessity. Nonetheless, the plaintiff can prevail if he shows that there is an alternative practice that meets the employers needs and has less of a disparate impact.
- Strong Basis in Evidence Standard
- An employer has to show that it conduct which creates a disparate impact is based on more than a fear of litigation.
- Rationale Not certifying the test was discrimination because it was a decision based on race. The city did not offer any reasonable alternatives to the test. The firefighters took the test at an expense to themselves.
- Dissent Justice Ginsburg disagreed with the majoritys premise that the test violated Title VIIs disparate treatment provision. Ginsburg recognized that the Court historically has held that the because of race language in Title VII, when interpreted with the spirit of the Civil Rights Acts, will not necessarily be used to protect non-minorities from discrimination.
- Ricci video
- Obama speaks on affirmative action
- Does the presence of the recession cause governments to unnecessarily trammel the rights of private contractors bidding for construction jobs?
- Should it be unconstitutional to apply affirmative action plans to women applying to law school?
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We start with the body and teach classic yoga postures with an emphasis on alignment so that strength and flexibility develop concurrently. Even after one's first class, a feeling of well-being is experienced as the ancient yogis and now modern science concur that there is a direct relationship between one's body and mind. From action and ...
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